The Commissioner’s latest view on transfer pricing documentation

The ATO has finalised its guidance on transfer pricing documentation and penalties under the new transfer pricing regime. For further information see PwC’s Tax Insights: Transfer Pricing (December 2014).

The ATO has also now published its online guidance in relation to ‘Simplifying transfer pricing record keeping’. If a taxpayer elects to apply a simplified record keeping option outlined in this guidance, Practice Statement Law Administration (PS LA) 2014/3 explains that the Commissioner will not review the taxpayer’s records beyond confirming its eligibility. This guidance provides effective safe harbours for small taxpayers, small- to-medium sized distributors, low-risk intragroup services and low-level intragroup loans. For  further information see PwC’s Tax Insi ghts:Transfer Pricing (January 2015).

Japan proposes action on Base Erosion and Profit Shifting (BEPS)

See PwC Japan’s Tax Update highlighting 2015 Tax Reform proposals including reduced corporate tax

rate and changes to implement some BEPS-related measures including removal of the dividend income exclusion for hybrid instruments.

United Kingdom's Proposed Diverted Profits Tax

See the PwC Tax Insights: Transfer Pricing and Tax Insights: International Tax Services publications on the United Kingdom Diverted Profits Tax (DPT). The tax will be at a rate of 25 per cent of profits arising on after 1 April 2015 that are considered to be artificially diverted from the United Kingdom.

Base erosion and profit shifting (BEPS) action plans

Access PwC material on the BEPS action plans.